Finding 15890 (2022-002)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-28
Audit: 19527
Organization: Bethany College (WV)
Auditor: Baker Tilly

AI Summary

  • Core Issue: The College failed to report changes in student enrollment status for all 25 students tested within the required 30-day timeframe.
  • Impacted Requirements: Compliance with Title IV regulations regarding timely updates to the National Student Loan Data System (NSLDS) is critical for maintaining accurate student loan records.
  • Recommended Follow-Up: The College should enhance its procedures for tracking student status changes and ensure regular reviews of NSLDS notifications to meet reporting deadlines.

Finding Text

Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loans Federal Agency: Department of Education Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 25 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The College's procedures for reporting students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the College review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the College. Management's Response: Management concurs with the finding and the College will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period.

Corrective Action Plan

Management's response to Finding 2022-002 Significant Deficiency- Student Status Changes Response: Bethany College accepts the finding that we have had an unplanned lapse in our enrollment reporting to NSLDS. This lapse is attributable to Bethany's monthly reporting to the National Student Clearinghouse. The National Student Clearinghouse information is submitted through the Student Status Confirmation Report process. The records are then updated with NSLDS. Due to transitions in the positions responsible for the reporting, the monthly uploads were not timely and resulted in sequent errors. Additionally, Bethany has had transitions in other offices that led to some of the identified issues regarding graduation dates and withdrawals. Due to the transitions, Lisa Reilly, Associate Provost of Academic Records and Accreditation, is now a key holder in the system. She had received training from the consortium that Bethany participants in for its database and has been working with National Student Clearinghouse on reports and updating student information. Two additional individuals will be identified and trained to process these reports by June 30, 2023. The institution will prepare a standard guide that will be used in the case of any transitions to prevent this this repeated pattern. The training guide will be completed by June 30, 2023. Reilly is working with National Student Clearinghouse on these corrections and aims to have them completed by March 31, 2023. By December 2023, Bethany will establish an internal audit of the submissions during this period of transition.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Other Findings in this Audit

  • 592332 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $34.60M
84.268 Federal Direct Student Loans $3.87M
84.038 Federal Perkins Loan Program $3.22M
84.063 Federal Pell Grant Program $1.17M
84.007 Federal Supplemental Educational Opportunity Grants $502,900
84.425 Education Stabilization Fund $74,449
84.033 Federal Work-Study Program $70,503
43.008 Education $11,000